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                                                            January 22, 2025

Michael B. Lucareli
Chief Financial Officer
Modine Manufacturing Company
1500 DeKoven Avenue
Racine, Wisconsin 53403

       Re: Modine Manufacturing Company
           Form 10-K for the Fiscal Year Ended March 31, 2024
           Form 8-K furnished October 29, 2024
           File No. 001-01373
Dear Michael B. Lucareli:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 8-K furnished October 29, 2024
Exhibit 99.1, page 1

1.     We note that you have presented Adjusted EBITDA as a non-GAAP measure
and
       have not provided equally prominent disclosure of net income or loss.
Item
       10(e)(1)(i)(A) of Regulation S-K requires a presentation having equal or
greater
       prominence of the most directly comparable financial measure calculated
and
       presented in accordance with GAAP, and a reconciliation between this
measure and
       your non-GAAP measure. Refer to C&DI 102.10 and revise your Adjusted
EBITDA
       presentation accordingly.



        In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.
 January 22, 2025
Page 2

       Please contact Heather Clark at 202-551-3624 or Jean Yu at 202-551-3305
with any
questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Manufacturing
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